Privacy Policy


Effective Date: 1st May, 2022

 

1. ABOUT LUXCLUSIF AND THIS PRIVACY POLICY

We are LUXIS BALTIC OÜ (“Luxclusif”, “we”, “us”, “our”), and we are committed to protecting your privacy.

Luxclusif is the controller for the purposes of the General Data Protection Regulation (the “GDPR”) a company registered in Estonia (Company No. 12824968), with its registered office located at Harju maakond, Jõelähtme vald, Loo alevik, Aasa tee 1, 74201 Estonia, and manages luxclusif.com (the “website”).

This Privacy Policy sets out the information that we collect, the reasons for which we collect that information, and how we can use and share that information.

The Website and the services provided by Luxclusif are not intended to be used by children. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, you can contact us at dataprivacy@upteamco.com.

 

2. WHAT INFORMATION DO WE COLLECT, AND HOW?

When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:

Depending on what you provide, this information can include your name and contact details such as phone number and email address. We may also collect information from your company, such as identification, contacts, addresses and tax and financial information.

You can see more details about the third parties we use in section 5.

 

3. WHAT DO YOU USE MY INFORMATION FOR?

To provide you services and the Website, including to administer your account and to optimize your experience we need to use the information that we collect in a number of different ways.

Please scroll down to find out the detailed purposes for which we collect your information, and what specific information is collected:

 

4. WHO DO YOU SHARE MY INFORMATION WITH?

To provide the Website and our services, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:

 

5. TRANSFERS OF YOUR PERSONAL DATA

To provide our Website and our services, in accordance with the purposes set out above, we may transfer and store the personal information that we collect from you to a destination inside or outside of the United States, mostly from and to the European Economic Area (“EEA”).

When transferring personal information to one of our third party services’ providers set out above, we rely on different adequacy and security measures to ensure we comply with the relevant privacy regulations.

 

6. COOKIES

We use technology such as “cookies” to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.

We use the following categories of cookies on our Website:

NECESSARY COOKIES These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details cannot be provided.

ANALYTICAL COOKIES These cookies collect anonymous information on how you use our Website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation. The data stored by these cookies does not show personal details from which your individual identity can be established.
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your Internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website.

You can withdraw your consent to these cookies at any time through the following options:

Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver advertisements tailored to your web preferences and usage patterns, so you may see a greater number of advertisements that are irrelevant to you and your preferences.

Many web browsers support Do Not Track technology. While we strive to offer you choices when you use our website and services, we do not promise that we will be able to receive or honor web browser Do Not Track signals.

 

7. SECURITY

Keeping you and your personal information secure is very important to us. We take a number of reasonable steps to try to protect the personal information that you provide, including:

 

8. HOW LONG WILL YOU USE MY INFORMATION FOR?

We retain the data you provide to us for as long as you have your account with us and thereafter for such period as you may have questions or a claim in relation to our services, notwithstanding any superior retention period that we may be obliged to observe in accordance with legal requirements applicable to us.

In some circumstances you can ask us to delete your data as set out below.

 

9. WHAT ARE MY PRIVACY RIGHTS?

You have certain rights in relation to the personal data we hold about you depending on local law. Some of these only apply in certain circumstances. Please note that we may require you to verify your identity before responding to any requests to exercise your rights and that can include asking a set of security questions to ensure it is you. When you have appointed someone else to do the request on your behalf, that person and/or organization needs to show a valid power of attorney issued by you.

If you are located within the EEA, the following rights apply to you:

Also note that you may exercise your right to restrict our processing the data whilst we consider your request as described below.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note, however, that we may retain the personal data if there are valid grounds under law for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case.
Where you have requested that we erase data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the data or providing links to the data to erase the data too.

You also have the right to object to our processing of data about you and we will consider your request if we are processing the data we hold about you (including where the processing is profiling) on the basis of our or a third party’s legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the data whilst we make the assessment on an overriding interest;

To exercise or to know more about these rights, please contact us at dataprivacy@upteamco.com. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances).

 

10. COMPLAINTS

If you have any questions or concerns about this Privacy Policy, please contact us by emailing us at dataprivacyinfo@upteamcoluxclusif.com.

Depending on the country you live or work, you may have the right to file a complaint with the competent supervisory authority.

 

11. UPDATES TO THIS POLICY

Any changes we may make to this Privacy Policy in the future will be posted on this page and/or, where appropriate, notified to you by email. Please check back regularly to keep informed of updates or changes to this Privacy Policy.